Permanent Establishment Risks following Manufacturing and Distributing Restructurings

Journal
OECD
Bulletin for International Taxation 2012 (Volume 66), No. 6
The author, in this article, determines the legal framework available to deal with permanent establishment risks following manufacturing and distributing restructurings, analyses various countries’ practice on this issue, notes the consequences of these findings for global organizations, and suggests measures that may be adopted to mitigate these risks.